HomeMy WebLinkAboutNCG200469_NOV_20190625ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
June 25, 2019
CERTIFIED MAIL: 70171070 00001776 2064
RETURN RECEIPT REQUESTED
Tri-State Scrap Metal, Inc.
Attn: John Gribble
79 Pond Road
Asheville, North Carolina 28806
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0478)
NPDES Stormwater General Permit NCG200000
Tri-State Scrap Metal, Inc.
Certificate of Coverage NCG200469
Buncombe County
Dear Mr. Gribble:
On June 12, 2019, Isaiah Reed from the Asheville Regional Office of the Division of Energy,
Mineral and Land Resources (DEMLR), conducted a site inspection for the Tri-State Scrap
Metal, Inc. facility located at 79 Pond Road, Buncombe County, North Carolina. A copy of the
Compliance Inspection Report is enclosed for your review. The site visit and file review
revealed that the subject facility is covered by NPDES Stormwater General Permit
NCG200000 under Certificate of Coverage NCG200469. Permit coverage authorizes the
discharge of stormwater from the facility to receiving waters designated as Hominy Creek,
a Class C waterbody in the French Broad River Basin.
As a result of the site inspection, the following permit conditions violation(s) are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has not been developed, recorded, or
properly implemented.
2) Qualitative Monitoring
Qualitative monitoring has not been conducted and recorded in accordance with permit
requirements.
D_E Qom.- North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778
r+awm cuwuw.
828.296.4800
3) Analytical Monitoring
Analytical monitoring has not been conducted and recorded in accordance with permit
requirements.
Requested Response:
You are asked to respond to this office, in writing, within 30 calendar days from receipt of
this notice. Your written response should include a reasonable explanation as to why the
aforementioned violations have occurred as well as a Plan of Action to prevent these
violations from recurring.
Thank you for your attention to this matter. This Office is considering sending a
recommendation for enforcement to the Director of the Division of Energy, Mineral & Land
Resources regarding these issues. Your above -mentioned response to this correspondence
will be considered in this process. This office requires that the violations, as detailed
above, be properly resolved. These violations and any future violations are subject to
a civil penalty assessment of up to $25,000 per day for each violation. Should you have
any questions regarding these matters, please contact Isaiah Reed or myself at (828) 296-
4500.
Sincerely,
Stanley E. A
Regional Engineer
Land Quality Section
Enclosure:
Inspection Report
ec: Alaina Morman, Environmental Specialist Alaina.mormanna,ncdenr.eov
Stanley E. Aiken- Regional Engineer stan.aikennncdenr.gov
Compliance Inspection Report
Permit: NCG200469
SOC:
County: Buncombe
Region: Asheville
Contact Person: John Gribble
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Effective: 02/02/15 Expiration: 12/31/19 Owner: Tri-State Scrap Metal Inc
Effective: Expiration: Facility: Tri-State Scrap Metal, Inc.
79 Pond Rd
Inspection Date:. 06/12/2019
Primary Inspector: Isaiah L Reed
Secondary Inspector(s):
Title:
EntryTime: 09:OOAM
Certification:
Asheville NC 28806
Phone: 828-670-9006
Phone:
Exit Time: 10:30AM
Phone: 828-296A614
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater Discharge COC
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3
Permit: NCG200469 Owner -Facility: Tri-State Scrap Metal Inc
Inspection Date: 06/12/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On June 12, 2019 this facility was inspected for compliance. I met with John Gribble and Sonya Gribble on site. During the
inspection, the following items were noted:
1) The Stormwater Pollution Prevention Plan has not been maintained and reviewed as required by the General Permit
NCG200000. The permittee is directed to immediately begin maintaining and reviewing the Stormwater Pollution Prevention
Plan as outlined in the General Permit (NCG200000).
2) The Stormwater Pollution Prevention Plan was not complete at the time of the inspection, and did not contain all elements
required by NCG200000. The permittee is directed to immediately complete the Stormwater Pollution Prevention Plan as
described in the General Permit.
3) No Qualitative or analytical monitoring has been conducted at the facility at the time of the inspection. The permittee
explained that he believed the facility had no stormwater discharge and that was why the facility did not have any
analytical/qualitative monitoring records. Upon inspection of the facility, the outfall was observed discharging at that time.
The permittee is directed to immediately begin analytical and qualitative monitoring as required by the General Permit.
Please give the above items your immediate attention.
Page 2 of 3
Permit: NGG200469 Owner. Facility: Tri-State Scrap Metal Inc
Inspection Dale: 06/12/2019 Inspection Type : Compliance Evaluation
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (LISGS) map?
# Does the Plan include a "Narrative Description of Practices'?
# Does the Plan include a detailed site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Reason for Visit: Routine
Yes No NA NE
•
❑ ❑ ❑
•
❑ ❑ ❑
■❑❑❑
❑
N ❑ ❑
❑
E ❑ ❑
❑
E ❑ ❑
❑■❑❑
■❑❑❑
❑
❑ ❑
■❑❑❑
❑■❑❑
❑■❑❑
❑■❑❑
■❑❑❑
❑
E ❑ ❑
Comment: The Stormwater Pollution Prevention Plan (SWPPP) has not been reviewed and kept up to date.
The SWPPP is also incomplete.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ 0 ❑ ❑
Comment: Qualitative monitoring has not been conducted at the facility.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment: Analytical monitoring has not been conducted at the facility.
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
❑
E ❑ ❑
# Were all outfalls observed during the inspection?
0
❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division?
❑
❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges?
❑
0 ❑ ❑
Comment
Page 3 of 3